California SB 253 & SB 261 Tracker

General Overview

• California now requires large companies to report climate information. Two 2023 laws reach any US-organized company with major revenue doing business in the state — public or private: SB 253 covers greenhouse-gas emissions; SB 261 covers climate-related financial risk.
• One law is live, the other is paused. SB 253 is in effect and first-year reporting is proceeding. SB 261 is enjoined while a First Amendment challenge plays out, so no one is currently required to file it.
• The first deadline is final: November 10, 2026. The state’s Office of Administrative Law (OAL) approved CARB’s implementing regulation on October 12, 2026, and CARB’s notice gives that day as its effective date. The date had been a proposal since June: the revised regulation carrying it published on July 27, 2026, was out for public comment through August 11, and went back to OAL on September 21 (OAL file 2026-0921-06).
• The promised filing tools are out. CARB said on July 21 that a voluntary online filing platform, a guidance document, and an instructional video would be ready by September 1, 2026. All three are now listed on CARB’s program pages: the guidance is dated September 1, and CARB describes the platform as not mandatory, with email submission as an alternative.
• Year one is a grace period, not a gotcha. CARB says it will accept first reports whether or not they carry third-party assurance, and it has said it will credit good-faith efforts. A company that wasn’t tracking emissions, and wasn’t planning to, when CARB’s December 2024 enforcement notice issued is asked to file a short letter saying so instead of a full report — that route comes from CARB’s September 1, 2026 guidance and from the regulation itself (§ 96076(b)(1), in effect since October 12), not from the 2024 notice, which addressed only incomplete reporting from data a company already had or was already collecting.
• The 2027 rules are taking shape. At a July 21, 2026 workshop, CARB proposed requiring only five of the fifteen Scope 3 categories in 2027, named the assurance standards it would accept, and moved to fold insurers in from 2027 — with five sector-by-sector listening sessions held August 5 through September 2 and a sixth listed as scheduled for September 9.

What is SB 253?

SB 253, the Climate Corporate Data Accountability Act, requires business entities organized under US law with more than $1 billion in total annual revenue that do business in California to publicly disclose their greenhouse gas emissions every year, measured under the GHG Protocol. Reporting begins in 2026 with Scope 1 and Scope 2 emissions for the prior fiscal year; Scope 3 reporting begins in 2027. The first-report deadline and the first-year options are set by CARB’s implementing regulation, in effect since October 12, 2026; for 2026, CARB accepts reports through a voluntary intake platform or by email.

What is SB 261?

SB 261, the Climate-Related Financial Risk Act, requires US-organized entities with more than $500 million in revenue doing business in California to prepare biennial climate-related financial risk reports consistent with a recognized framework (TCFD, IFRS S2, or an equivalent government-mandated regime). It is currently enjoined pending appeal, so no deadline is being enforced — though CARB’s voluntary docket remains open through December 31, 2026, and more than 100 companies have filed.

The deadline history — and why it moved

The first SB 253 deadline was scheduled three times before it became final: CARB staff initially floated June 30, 2026; the regulation the Board adopted in February set August 10, 2026; and CARB’s June 24 bulletin proposed November 10, 2026 — the date in the regulation OAL approved on October 12. The mechanism behind the last move was procedural: CARB submitted its adopted Initial Regulation to OAL on May 20, withdrew it on June 23 to make limited clarifying changes, and deferred the deadline by three months so that reporting entities would have additional time after formal adoption. OAL approved the resubmitted package on October 12, twenty-one days after receiving it. The 2026 deadline is now fixed in regulation; the dates still in motion are the 2027 ones previewed below, which is why a dated, change-logged tracker rather than a point-in-time alert is the way to follow this program.

What must be in the 2026 report

Scope 1 covers emissions from sources the company owns or controls — fuel combustion, process emissions, fugitive emissions. Scope 2 covers indirect emissions from purchased energy. Scope 3 — the value chain — is not part of the 2026 report; it begins in 2027 under a separate rulemaking now in progress.

Who files, and at what level

Coverage turns on three elements: US organization, the revenue threshold, and “doing business in California” (the regulation’s definition, § 96072(a)(7)–(8), tracks Revenue and Taxation Code § 23101, the Franchise Tax Board’s doing-business test). A parent — including a foreign parent, per CARB staff guidance — may file a consolidated report covering its in-scope US subsidiaries, though fees are assessed per in-scope entity even under consolidated reporting. Public-company status is irrelevant: private companies meeting the tests are covered on the same terms.

The trigger event happened: the 15-day changes, and what they do

The publication this page had been waiting on arrived on July 27, 2026, when CARB posted a Notice of Public Availability of Modified Text alongside the 15-Day Proposed Regulation Text. The comment period closed August 11, 2026. CARB resubmitted the package to OAL on September 21, 2026 — OAL file 2026-0921-06, “Cal. GHG Reporting and Climate Risk Disclosure Regulation,” a Regular Resubmittal — and OAL approved it on October 12, 2026. CARB’s notice of that day gives October 12 as the regulation’s effective date. The provisions below are therefore no longer proposals. They are quoted here as they read in the Final Regulation Order CARB resubmitted on September 21, checked on October 13; CARB’s addendum to its Final Statement of Reasons describes the changes made after the 15-day notice as non-substantial corrections of typography, grammar, numbering and formatting. OAL’s endorsed copy and the published California Code of Regulations text were not available to check.

Five changes matter for anyone scoping a 2026 filing.

First-year relief is now in the regulation text. This was the open question law-firm alerts kept flagging. Section 96076(b)(1) writes the December 5, 2024 notice’s data option into the regulation text and adds a letterhead non-reporting option, which the notice did not contain. For the November 10, 2026 report only, an entity may submit either of two things in lieu of the reporting required by § 96076(a): (A) Scope 1 and Scope 2 emissions for the prior fiscal year “that can be determined from information the reporting entity already possesses or was already collecting on or before December 5, 2024”; or (B) a statement on company letterhead that it is not reporting because it neither possessed that information nor was collecting it by that date. Note the second limb of (A) — “was already collecting” reaches an entity that had a collection process running even if it had no finished figures. Note too that (B)’s test is not the one CARB’s guidance describes: the regulation keys the letter to not possessing and not collecting the information, while the guidance asks for it from an entity that was not collecting data and was not planning to collect it when the notice issued.

Scope 3 is expressly not required for 2026. Previously an inference from the statute’s 2027 start; § 96076(a) now says it outright: “Scope 3 emissions reporting is not required for 2026 reporting.”

The revenue test narrowed. Under § 96072(a)(13), “revenue” carries the meaning of “gross receipts” in Revenue and Taxation Code § 25120(f)(2), is evaluated at the individual business-entity level, and excludes intercompany transactions between entities of the same combined reporting group as described in 18 CCR § 25106.5-1. A group that cleared the $1B or $500M threshold partly on internal flows may now fall outside it — which makes re-running the coverage test a live exercise, not a settled one. “Doing business in California” (§ 96072(a)(8)) is likewise now evaluated entity by entity.

A parent can file once for the group. Under § 96076(a), reports “may be consolidated at the parent company level,” and a subsidiary that independently qualifies as a reporting entity under § 96072(a)(11) “is not required to prepare a separate report” where the parent consolidates. Fee payment may be consolidated the same way, keyed to § 96072(a)(5).

The 2026 fee clock moved. The Executive Officer’s written fee determination notice shifts from September 10 to December 10, 2026, with payment due “within 60 calendar days of the fee determination notice date” — the notice date, not the date of receipt, which is the stricter reading of the two.

Two narrower definitional changes round it out, both in § 96072(a)(8): wholesale sales of electricity occurring in interstate commerce do not count toward an entity’s California sales under R&TC § 23101(b)(2), and the word “taxpayer” in R&TC § 23101(b) “is substituted with the term ‘business entity’” — which matters for entities that are not themselves taxpayers.

CARB also committed at the July 21 workshop to filing infrastructure by September 1, 2026 — a voluntary online intake platform for fee contact information and emissions reporting, a guidance document, and an instructional video. All three are now posted. CARB’s Corporate Climate Data and Resources pages link a Guidance for SB 253 2026 Reporting Submittals dated September 1, 2026, a “2026 Report Intake Platform,” and a video tutorial walking through the platform; the Resources page dates the set 9/1/2026. The materials are listed on CARB’s newer Corporate Climate Data and Resources pages, not on the older program, news, and resources URLs, which as of September 15 still do not list them.

What the guidance says, in CARB’s framing:

• The platform is optional. Use of the platform “is not mandatory”; entities may instead submit by email to climatedisclosure@arb.ca.gov. The platform collects contact and billing information for fee invoicing, with optional fields for Scope 1 and 2 emissions.
• Accepted 2026 formats. An existing annual report that includes Scope 1 and 2 emissions; existing Scope 1 and 2 data reported to other programs or voluntary initiatives; or CARB’s Draft Scope 1 and 2 Template, whose use is voluntary for 2026.
• Entities without data. An entity that was not collecting Scope 1 and 2 information as of December 5, 2024, and was not planning to collect it when the December 2024 Enforcement Notice was issued, is asked to submit a statement of non-reporting on company letterhead, through the platform or by email, before November 10, 2026. The guidance states that CARB “recommends this approach”; that is CARB’s position, reported here, not Regbase’s.
• Assurance. The guidance notes that the statute “requires limited assurance beginning in 2026,” and that, given first-year enforcement discretion, CARB “will accept submissions whether or not assurance has been obtained for the 2026 cycle.”
• Scope 2 emission factors. The guidance says the Initial Regulation “would not require” a specific emission-factor dataset for 2026; it names U.S. EPA’s eGRID 2023 or the eGRID 2024 dataset published by the Cornerstone Sustainability Data Initiative, and allows other credible sources.

Two features of the guidance reflect its date, about six weeks before approval. It describes the Initial Regulation as applying “if approved by the Office of Administrative Law,” and it grounds first-year flexibility in the December 2024 Enforcement Notice and CARB’s FAQ rather than in § 96076(b)(1), stating that it “reflects CARB’s discretion in enforcing compliance during the transition period and does not constitute an interpretation of statutory reporting requirements.” It also says it “may be updated.” CARB’s October 12 approval notice links the same September 1 document. CARB’s October 2026 reminder letter to organizations that may be covered, by contrast, cites § 96076(b) for both first-year options, and calls the intake platform “the preferred method for submitting required disclosures” while saying its use “is not required for first-year reporting.” Neither the notice nor the letter addresses the difference between the guidance’s test for the non-reporting letter and the regulation’s.

The 2027 regime is taking shape — the July 21 workshop

The same workshop previewed the “Subsequent Regulation” — the separate rulemaking that will govern reporting in 2027 and beyond — in the most concrete terms so far. Three proposals stand out. Scope 3 starts narrow: responding to feedback that assessing all fifteen GHG Protocol categories from 2027 poses data-availability and cost problems, staff propose requiring only the five most commonly reported categories — purchased goods and services (Category 1), fuel- and energy-related activities (Category 3), waste generated during operations (Category 5), business travel (Category 6), and employee commuting (Category 7) — with the other ten voluntary. Assurance gets named standards: beginning with reports submitted in 2027, Scope 1 and 2 disclosures require limited assurance from an independent third party conducted in full conformance with one of five standards — AA1000AS v3, AICPA AT-C Section 210, ISAE 3410 in conjunction with ISAE 3000 (Revised) for engagements commencing before December 15, 2026, ISSA 5000 for engagements commencing on or after that date, or ISO 14064-3:2019 with additional accreditation requirements; a reasonable-assurance engagement satisfies the requirement. Insurers come off the sidelines (next section). All of this is proposal-stage — as of September 15, CARB’s Regulation page lists only the Initial Regulation, and the Subsequent Regulation has not been formally proposed — but the workshop set its schedule: the staff proposal (staff report, economic analysis, and full draft regulatory text) publishes this fall for a 45-day public comment period, with Board consideration targeted by the end of the year, and six sector-specific listening sessions set for August 5 through September 9, 2026 before it lands. Five of the six have now been held — data users and public-interest stakeholders (August 5); manufacturing, industrial, fuel and life sciences (August 12); agriculture, food, beverage and forestry (August 19); energy, utilities, transportation, logistics and waste (August 26); and retail, consumer goods, technology and commercial services (September 2) — with banking, finance and insurance scheduled to close the series on September 9. As of September 15, CARB’s meetings page still lists that sixth session under “Upcoming Events” with no recording posted, so this page has not confirmed that it took place as scheduled. Recordings for the first five sessions are posted on the meetings page (linked below).

Four further points from the workshop Q&A worth having on record. Staff propose November 10 as the recurring annual reporting deadline for 2027 and onward, not just 2026 — explicitly open to feedback. The baseline year would be 2027, the first year of reporting under the program. The five required Scope 3 categories come with a data-exclusions provision — emissions may be excluded where the omission could not reasonably be expected to influence users’ understanding, applying the GHG Protocol’s five accounting principles — so “required” is not “exhaustive,” and staff confirmed the statute limits Scope 3 penalties to non-filing between 2027 and 2030 (HSC § 38532(f)(2)(C)). And on interoperability’s limits: because California regulations cannot dynamically incorporate a standard’s future revisions, CARB will freeze references at the versions in effect at adoption — notably the 2015 Scope 2 guidance, not the pending GHG Protocol update. The workshop slides, notice, and recording are linked in the primary sources below.

First-year flexibility: what CARB has said, and where it lives

It is now in the regulation. For most of this program’s life, first-year relief sat in enforcement statements — CARB’s repeated assurance that it would exercise discretion for good-faith submissions, plus the December 5, 2024 enforcement notice, which allowed a first report built from Scope 1 and 2 information the entity already possessed or was already collecting when the notice issued. Law-firm alerts consistently flagged the gap: discretion can be withdrawn without process, and commenters at the February 2026 hearing asked CARB to codify it.

The 15-day changes posted July 27, 2026 wrote the relief into § 96076(b)(1), and OAL’s October 12, 2026 approval put that text in force. For the November 10, 2026 report only, the requirement may be met three ways: a full report; Scope 1 and Scope 2 emissions “that can be determined from information the reporting entity already possesses or was already collecting on or before December 5, 2024”; or a statement on company letterhead that the entity is not reporting because it neither possessed that information nor was collecting it by that date — both limbs, not either one. CARB’s September 1, 2026 guidance, written before approval, grounds 2026 flexibility in enforcement discretion under the December 2024 notice rather than in § 96076(b)(1); CARB’s October 2026 reminder letter cites the regulation. What approval changed is the relief’s legal footing, not its substance. Regbase describes the options; whether and how a particular company relies on one is a question for counsel against the regulation text itself.

Settled vs. proposed

Settled (statute): the $1B and $500M thresholds, annual Scope 1 & 2 disclosure from 2026, Scope 3 from 2027, the GHG Protocol as the measurement framework, and penalties up to $500K (SB 253) and $50K (SB 261) per year. SB 253 remains in effect — the Ninth Circuit declined to enjoin it.

Settled (regulation, approved October 12, 2026): the November 10, 2026 deadline (§ 96076(a)), the fee formula and the December 10 fee-notice date (§§ 96073–96074), the “doing business in California” definition and the entity-level revenue test (§ 96072), parent-level consolidated reporting, and the first-year options at § 96076(b)(1). These were proposals until OAL approved the package CARB resubmitted on September 21; CARB’s notice gives October 12, 2026 as the effective date.

Previewed only (Subsequent Regulation, not yet proposed): the 2027 Scope 3 phase-in, the named assurance standards, insurer treatment from 2027, the recurring November 10 deadline, and the 2027 baseline year. Staff proposal due this fall on a 45-day comment period.

Ongoing litigation

In U.S. Chamber of Commerce v. Sanchez, No. 25-5327, business groups challenge both laws, principally on First Amendment grounds. The district court denied a preliminary injunction in August 2025; on November 18, 2025, the Ninth Circuit enjoined SB 261 pending appeal but declined to enjoin SB 253. Oral argument was held January 9, 2026 — with the panel probing whether emissions reporting is factual operational data or compelled ideological speech — and a ruling is awaited: as of September 15, no decision appears on the CourtListener mirror of the Ninth Circuit docket, whose most recent entry is a June 26, 2026 filing (the mirror was last updated August 7; the court’s own docket was not checked). If the Ninth Circuit affirms the denial as to SB 261, the appellate injunction dissolves and CARB can reinstate SB 261 enforcement. Summary-judgment proceedings continue in the district court in parallel.

The insurance-exemption question

A gray area that just moved: SB 261’s statute expressly addresses insurance companies; SB 253’s statute contains no express carve-out; yet the regulation exempts insurers from both programs — § 96071(b)(2) in the approved text, as in the version withdrawn in June. At the February hearing — over objections from the laws’ own authors — the Board retained the exemption but directed staff (Resolution 26-1) to evaluate it with the Department of Insurance. On July 21, staff reported back: CDI reporting may not satisfy SB 253 in future years, because it includes neither Scope 3 nor assurance. Their proposal — beginning in 2027, insurers may submit one report satisfying both CDI and SB 253 requirements, supplementing wherever the CDI report falls short of CARB’s regulation. The 2026 exemption stands; the 2027 treatment awaits the Subsequent Regulation’s formal proposal.

How companies are preparing

Before the October 12 approval, law-firm alerts broadly converged on treating November 10, 2026 as the working target while flagging that it was proposed, not settled; on continuing Scope 1 & 2 data assembly under the GHG Protocol on the prior fiscal year; and on documenting what was being collected as of December 5, 2024, given how CARB has described its first-year expectations. This page has not surveyed alerts issued since approval. On the SB 261 side, the 100+ voluntary filings show a substantial cohort proceeding despite the injunction. Regbase reports these observable postures; it does not advise on them.

FAQ

What exactly is due on November 10, 2026? The first annual SB 253 report: Scope 1 and Scope 2 emissions for the applicable preceding fiscal year, measured under the GHG Protocol. The date is set by 17 CCR § 96076(a), in the regulation OAL approved on October 12, 2026. For this first report only, § 96076(b)(1) allows the two alternatives described under first-year flexibility above.

Could the deadline move again? It is no longer a proposal. November 10, 2026 is written into the regulation OAL approved on October 12, 2026, which CARB says took effect that day. CARB moved the date twice while it was still a proposal — June 30, then August 10, then November 10. This page reports the regulation as approved; it does not predict whether a later rulemaking, legislation or litigation could change the date.

Do we need third-party assurance for the first report? CARB’s September 1, 2026 guidance notes that the statute requires limited assurance beginning in 2026, but says that, given first-year enforcement discretion, CARB will accept 2026 submissions whether or not assurance has been obtained. Limited assurance phases in for later years, with reasonable assurance from 2030 under the statute (HSC § 38532).

Is Scope 3 part of the 2026 report? No — Scope 3 begins in 2027 under the separate Subsequent Regulation, whose staff proposal is due this fall with a 45-day comment period; Board consideration is targeted by the end of 2026.

Is SB 261 enforceable right now? No — it is enjoined pending appeal, and no deadline is being enforced. CARB’s voluntary docket remains open through December 31, 2026.

What if we never started collecting emissions data? CARB’s September 1, 2026 guidance asks an entity that was not collecting Scope 1 and Scope 2 data as of December 5, 2024, and was not planning to collect it when the enforcement notice issued, to submit a statement of non-reporting on company letterhead — through the intake platform or by email — before November 10, 2026. The regulation, in effect since October 12, 2026, carries a letterhead route of its own at § 96076(b)(1), on a slightly different test — an entity that neither possessed the information nor was collecting it by that date. The guidance, written before approval, frames the option as enforcement discretion. The December 2024 enforcement notice itself did not create a letter option: it allowed a first report built from data the entity already possessed or was already collecting.

Are private companies covered? Yes. Coverage turns on US organization, revenue, and California nexus — not public-company status.

Changelog

• October 13, 2026 — OAL approved the Initial Regulation on October 12; November 10, 2026 is final. CARB’s October 12 notice reads: “Today, the California Office of Administrative Law (OAL) approved the California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation,” and “The effective date of the Initial Regulation is October 12, 2026.” Checked on October 13: that notice; OAL’s under-review list, which no longer carries file 2026-0921-06; OAL’s recent-actions list, which now does but gives no outcome; OAL’s disapproval-decisions index, which does not list the file; CARB’s rulemaking page, which still shows “Final Approval / OAL Action” as not yet reached; the Final Regulation Order CARB resubmitted on September 21 (17 CCR §§ 96070–96077, read in full); the introduction and non-substantial-modifications section of CARB’s Final Statement of Reasons Addendum; CARB’s September 18 Request for an Early Effective Date; CARB’s September 1 guidance (re-read); CARB’s June 24 bulletin; and CARB’s October 2026 reminder letter to organizations that may be covered. Updated the description, status pills, first-deadline line and status line; the first-deadline, implementing-regulation, penalties-and-fees and open-questions rows; the General Overview; “What is SB 253?”; the deadline history; the 2026 report table; the 15-day-changes, first-year-flexibility, settled-vs-proposed, who-files, insurance and how-companies-are-preparing sections; and three FAQs. Corrected: CARB withdrew the first OAL package on June 23, 2026, per its Final Statement of Reasons Addendum; this page had given June 24, which is the date CARB announced the withdrawal, and its deadline-history section had counted thirty-five days from May 20 where the interval is thirty-four. Earlier changelog entries keep their original wording. Added: the § 96076(c) rule on which fiscal year the first report covers, and a note that § 96073 sets a fee formula rather than a dollar amount. Re-read against the Final Regulation Order: §§ 96071(b)(2), 96072(a)(7)–(8) and (a)(13), 96074(a)–(b), and 96076(a)–(c) read as this page had reported them from the 15-day text. Not re-checked this pass: OAL’s endorsed copy of the regulation, any OAL notice of approval, and the published California Code of Regulations text — none was available, so the approval and the effective date rest on CARB’s notice, with OAL’s lists consistent with it; the fee estimates (~$3,106 and ~$1,403); the September 10 date the fee notice moved from (the 15-day text was not re-read); the June 30 first-floated date; the December 26, 2025 proposal date in the lifecycle (CARB’s rulemaking page shows the hearing notice as posted December 23, 2025; the difference was not resolved this pass); the Ninth Circuit docket and the district-court proceedings; everything about the Subsequent Regulation, the listening sessions and the 2027 proposals; the SB 261 voluntary-filing count; the insurance history beyond § 96071(b)(2); HSC § 38532; the December 2024 enforcement notice; and law-firm alerts issued since approval.
• September 24, 2026 — CARB’s rulemaking page now confirms the September 21 resubmission; still under OAL review. Checked on September 24: OAL’s “Proposed Regulations Currently Under Review” list still carries file 2026-0921-06, Air Resources Board, as a Regular Resubmittal (SR); OAL’s recent-actions list shows no decision on it; and CARB’s rulemaking page now reads “The Final Package was resubmitted to OAL on September 21, 2026,” listing a Final Statement of Reasons Addendum, an Updated Informative Digest, Executive Order R-26-006, the Final Regulation Order and a Request for Early Effective Date, with “Final Approval / OAL Action” still not yet reached. November 10 remains proposed. Updated the status line and the implementing-regulation row. Also reworded the status line, the General Overview, the filing-infrastructure section and the September 2 and September 15 entries to state current status rather than narrate earlier corrections; no facts changed. Not re-checked this pass: everything else on the page, which stands as verified on September 15 and 23.
• September 23, 2026 — CARB resubmitted the Initial Regulation to OAL. OAL’s “Proposed Regulations Currently Under Review” list now carries file 2026-0921-06, Air Resources Board, “Cal. GHG Reporting and Climate Risk Disclosure Regulation,” file type Regular Resubmittal (SR); OAL numbers files by the date received, September 21, 2026. Checked on September 23: that OAL list, and CARB’s rulemaking page, which still shows “Final Approval / OAL Action” as not yet reached and says the withdrawn May 20 package “will be resubmitted” — CARB’s page lags OAL’s. November 10 remains proposed until OAL approves. Updated the description, status pill, status line, the first-deadline, implementing-regulation and open-questions rows, the General Overview, the trigger-event section, the settled-vs-proposed section and the November 10 FAQ. Not re-checked this pass: everything else on the page, which stands as verified on September 15; OAL’s review deadline for the resubmittal (the statute was not reachable during this check, so no decision date is given).
• September 15, 2026 — CARB’s 2026 filing guidance, intake platform and video tutorial are posted; OAL stage unchanged. Checked on September 15: CARB’s rulemaking page, Corporate Climate Data page, Resources page, Regulation page, and climate-disclosure meetings page; the older program, news, and resources URLs; the September 1, 2026 guidance PDF (read in full); §§ 96072(a)(13), 96074(a), and 96076 of the 15-day proposed regulation text; the July 21 workshop slides (September 1 commitment); the December 5, 2024 enforcement notice; HSC § 38532 (assurance levels); the video tutorial’s YouTube listing (title, channel, and upload date only); OAL’s home page; and the CourtListener mirror of Ninth Circuit docket No. 25-5327. CARB’s Corporate Climate Data page links a “2026 SB 253 Reporting Guidance document,” a “2026 Report Intake Platform,” and a video tutorial, and its Resources page lists the same three under a 9/1/2026 heading; they do not appear on the older program, news, and resources URLs. Updated the status line; the filing-support, implementing-regulation, litigation, assurance, and open-questions rows; the General Overview; the trigger-event and filing-infrastructure sections (the latter now summarizing the guidance); the “Assurance” and “Where filed” table rows; the 2027-workshop section (Regulation-page check, listening-session status); the Ongoing litigation section; the assurance and no-data FAQs; and the primary-sources list. The status-bar primary-source link now points to CARB’s Corporate Climate Data page. Assurance: the at-a-glance row, table, overview, and FAQ report CARB’s guidance, which notes the statute requires limited assurance beginning in 2026 but says CARB will accept 2026 submissions with or without it. The 2030 reasonable-assurance date is attributed to the statute, HSC § 38532, which sets it. The FAQ on entities without data now reflects both the guidance and the proposed-but-unapproved § 96076(b)(1). Clarified: the non-reporting letter option comes from the September 1, 2026 guidance and the proposed § 96076(b)(1) — the December 5, 2024 enforcement notice allowed only a first report built from information the entity already possessed or was already collecting; the first-year relief sits in proposed text that OAL has not approved; the data route covers information the entity “already possesses or was already collecting,” and the letter route requires both not possessing and not collecting; and fees are due 60 calendar days from the fee determination notice date (§ 96074(b)). Also drawn: the guidance asks for the non-reporting letter from an entity that was not collecting data and was not planning to collect it when the notice issued, while § 96076(b)(1) keys its letterhead option to an entity that neither possessed the information nor was collecting it — different tests, now reported as such. Unchanged: the 15-day text’s December 10 fee-notice date (§ 96074(a)) and entity-level revenue test (§ 96072(a)(13)) read as previously reported; the rulemaking page still shows “Final Approval / OAL Action” as not yet reached and the May 20 package as withdrawn and to be resubmitted, so November 10 remains proposed; CARB’s Regulation page lists only the Initial Regulation, so the Subsequent Regulation has still not been formally proposed. The sixth listening session (banking, finance and insurance, September 9) is still listed under “Upcoming Events” with no recording, so whether it took place is not confirmed. Ninth Circuit: no decision on the CourtListener mirror (latest entry June 26, 2026; mirror last updated August 7). Added: a direct link to CARB’s 2026 Report Intake Platform (Survey123), pulled from CARB’s Resources page and cross-checked against CARB’s September 1, 2026 GovDelivery notice; the page previously named the platform without linking to it because the Survey123 page did not render for automated fetch. Added: the statutory window for the Scope 3 non-filing limit — HSC § 38532(f)(2)(C) confines it to 2027 through 2030 — in the “Penalties & fees” row and the 2027-workshop section. Not re-checked this pass: the Ninth Circuit’s own docket or PACER; district-court summary-judgment proceedings; OAL matter-level records (only OAL’s home page, which names no SB 253/261 action); the SB 261 voluntary-filing count; fee amounts; the 15-day text beyond §§ 96072(a)(13), 96074(a), and 96076; the CARB FAQ; the intake platform’s on-screen form fields (Survey123 is a JavaScript app; its URL is now linked, but its contents are still not independently verified beyond the guidance PDF’s description); the video tutorial’s contents; the July 21 workshop notice and recording (only the slides were re-read); and the law-firm postures described under “How companies are preparing.”
• September 2, 2026 — Comment period closed August 11; listening series nearly complete. The 15-day comment period on the revised Initial Regulation closed August 11, 2026. Checked against CARB’s rulemaking page on September 2: the “Final Approval / OAL Action” stage is still marked not yet reached and the May 20 package is still shown as withdrawn pending resubmission, so November 10 remains proposed. The Subsequent Regulation listening series is five sessions in: data users and public-interest stakeholders (Aug. 5), manufacturing/industrial/fuel/life sciences (Aug. 12), agriculture/food/beverage/forestry (Aug. 19), energy/utilities/transportation/logistics/waste (Aug. 26), and retail/consumer goods/technology/commercial services (Sept. 2); banking, finance and insurance closes the series September 9. Verified against CARB’s climate-disclosure meetings page and the August–September listening-session notice (linked below). Pill updated from “15-day comment closes Aug 11” to reflect the closed period and pending OAL resubmission. Ninth Circuit: still no ruling.
• August 4, 2026 — The revised Initial Regulation published July 27; comments close August 11. CARB posted a Notice of Public Availability of Modified Text and the 15-Day Proposed Regulation Text on July 27, 2026 — the trigger event this page had been tracking as pending. Five substantive changes: first-year relief is written into the proposed regulation text (full report; data the entity already possessed or was already collecting on or before the December 5, 2024 notice; or a letterhead statement that it neither possessed nor was collecting it) — wording corrected September 15, 2026, this entry originally said “codified” and omitted the “already collecting” limb; Scope 3 expressly not required for 2026, the revenue test narrowed (measured at individual business-entity level; intercompany transactions within a combined reporting group excluded), parent-level consolidated reporting permitted with subsidiaries that independently qualify relieved of separate filing, and the 2026 fee determination notice moved from September 10 to December 10, 2026 with payment due within 60 calendar days of the fee determination notice date (corrected September 15, 2026 — this entry originally said 60 days after receipt; § 96074(b) keys the period to the notice date). Two definitional changes: the wholesale-electricity exclusion now applies only to interstate-commerce transactions, and “doing business in California” is framed around a “business entity” rather than a “taxpayer.” November 10 remains proposed pending OAL approval. Corrects this page’s prior statement that the revised text and its comment notice remained unpublished — that was accurate when written on July 28 but the notice had posted the day before. Ninth Circuit: still no ruling.
• July 28, 2026 — CARB’s July 21 workshop previewed the 2027+ regime and set a September 1 date for 2026 filing infrastructure. Scope 3 phase-in proposed: only five of fifteen GHG Protocol categories required in 2027 (purchased goods & services, fuel- and energy-related activities, waste, business travel, employee commuting), the rest voluntary. Limited assurance of Scope 1 & 2 proposed from 2027 reports under five named standards (AA1000AS v3, AICPA AT-C 210, ISAE 3410/3000 pre-Dec. 15 2026, ISSA 5000 after, ISO 14064-3:2019). Insurance update per Board Resolution 26-1: staff found CDI reporting may not satisfy SB 253 from 2027 and propose a single dual-purpose report, supplemented where CDI falls short. CARB committed to a voluntary online intake platform, guidance document, and instructional video by September 1, 2026; six sector listening sessions run August 5–September 9. From the workshop Q&A: the Subsequent Regulation’s staff proposal (staff report, economic analysis, full draft text) publishes this fall for a 45-day comment period, with Board consideration targeted by year-end; November 10 is proposed as the recurring annual deadline for 2027+; the baseline year would be 2027; the five required Scope 3 categories carry a data-exclusions provision, and the statute limits Scope 3 penalties to non-filing; regulatory references will freeze at versions in effect at adoption — notably the 2015 Scope 2 guidance, not the pending GHG Protocol update. The revised Initial Regulation and its 15-day comment notice remain unpublished — November 10 is still proposed, not final. Verified against CARB’s workshop slides, public notice, and full recording/transcript (linked below); full analysis →. Ninth Circuit: still no ruling.
• July 13, 2026 — Accuracy and format pass. Corrected the SB 261 voluntary-filing count to 100+ (previously overstated as 170+); updated the CARB program, rulemaking, and enforcement-notice links to the renamed program pages; repointed the Ninth Circuit docket link (case No. 25-5327 confirmed); added the plain-English summary section.
• July 8, 2026 — Page launched. Current status: revised regulation text and 15-day comment notice not yet published; no Ninth Circuit ruling. Regulation lifecycle to date: December 26, 2025 proposal → February 26, 2026 adoption → May 20 OAL submission → June 24 withdrawal for revision. Fee notices to be issued by September 10 with 60 days to pay; 100+ voluntary SB 261 filings.

Primary sources: CARB notice of OAL approval (Oct. 12, 2026) · Final Regulation Order, 17 CCR §§ 96070–96077 (CARB, resubmitted to OAL Sept. 21, 2026) · Final Statement of Reasons Addendum (CARB) · Request for an Early Effective Date (CARB, Sept. 18, 2026) · OAL — recent actions on proposed regulations · CARB reminder letter to potentially covered organizations (Oct. 2026) · CARB Corporate Climate Data — 2026 report submission · Guidance for SB 253 2026 Reporting Submittals (CARB, Sept. 1, 2026) · 2026 Report Intake Platform (CARB, Survey123) · 2026 Report Intake Platform video tutorial (CARB) · CARB climate-disclosure resources · CARB climate-disclosure regulation page · CARB Climate Disclosure Program · July 21, 2026 workshop slides (CARB) · July 21 workshop notice (CARB bulletin) · July 21 workshop recording · CARB climate-disclosure meetings & workshops — Aug.–Sept. 2026 sector listening sessions (slides, recordings) · Listening-session notice, Aug.–Sept. 2026 (CARB PDF) · CARB program news (June 24, 2026 deadline deferral) · CARB SB 253/261 rulemaking materials — incl. the July 27, 2026 Notice of Public Availability of Modified Text and 15-Day Proposed Regulation Text · CARB FAQ (updated June 2026) · CARB enforcement notice (Dec. 5, 2024) · Case docket — Chamber of Commerce v. Sanchez, No. 25-5327 (Climate Case Chart) · Ninth Circuit docket No. 25-5327 (CourtListener mirror) · HSC § 38532